Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
ITAT allowed the taxpayer's claim for deduction of expenditure incurred in an abandoned project, recognizing that the project abandonment was due to reasons beyond the assessee's control. The tribunal held that the written-off expenses under 'work in progress' were commercially justified and not subject to tax authority scrutiny. The tribunal directed the Assessing Officer to delete the disallowance in both the section 143(1) intimation and section 143(3) assessment order, effectively permitting the expenditure deduction based on the commercial reasonableness of the assessee's decision.
ITAT allowed the taxpayer's claim for deduction of expenditure incurred in an abandoned project, recognizing that the project abandonment was due to reasons beyond the assessee's control. The tribunal held that the written-off expenses under 'work in progress' were commercially justified and not subject to tax authority scrutiny. The tribunal directed the Assessing Officer to delete the disallowance in both the section 143(1) intimation and section 143(3) assessment order, effectively permitting the expenditure deduction based on the commercial reasonableness of the assessee's decision.
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